Sarah Goolden v. Hamed Wardak

November 26, 2025 By ECF Honorable Valerie Figueredo MEMO ENDORSED United States Magistrate Judge oy . | United States District Court \} N \ ML Xx Southern District of New York VALERIE FIGUEREDO 7-7” Thurgood Marshall United States Courthouse UNITED STATES MAGISTRATE JUDGE Foley Square Dated: December 2, 2025 New York, NY 10007 Defendant filed ECF No. 276 and the exhibit ex Re: Sarah Goolden v. Hamed Wardak | parte. Defendant is directed to file ECF No. 276 1:19 Civ. 06257 (ALC) (VF) and the exhibit with redactions to any privileged information at the "selected parties" Dear Judge Figueredo: viewing level so it may be accessed by Plaintiff.

We represent the defendant, Hamed Wardak (“Defendant”) in the above-referenced matter.

Defendant respectfully submits this letter motion in accordance with this Court’s Individual Practice Rule I.G and Local ECF Rules and Instructions, Section 6.

Defendant respectfully requests that the Court seal the unredacted copies of Defendant’s legal invoices (the “Invoices”) in connection with his Reply Memorandum of Law in Further Support of Motion for Attorneys’ Fees, which Defendant will file contemporaneously with this Letter Motion.

“Although the presumption of public access attaches to all judicial documents, ‘the presumption of public access in filings submitted in connection with discovery disputes ... is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions.” Richards v. Kallish, No. 22 Civ. 9095, 2023 WL 7126311, at *1 (S.D.N.Y. Oct. 30, 2023) (quoting Brown v. Maxwell, 929 F. 3d 41, 47-48 (2d Cir. 2019)).

Courts in this District routinely seal documents to prevent the disclosure of a party’s confidential business information, as well as attorney-client privileged information. See, e.g., Weiss v. Yotta Technologies, Inc., No. 22 Civ. 8569, 2025 WL 1190807, at *6 n.4 (S.D.N.Y. Apr. 22, 2025) (granting letter motion to seal unredacted copies of attorney invoices that “contain[ed] attorney work product and privileged communications”); Richards, 2023 WL 7126311, at *2 (“[C]ourts often choose to review invoices and billing records in camera when calculating awards of attorneys fees and costs.”) (collecting cases).

Here, the documents for which sealing is requested are unredacted attorney invoices. They contain confidential information regarding work done by counsel and choices and priorities given to work by counsel, among other things. Accordingly, Defendant respectfully requests that the Court enter an order directing that Defendant’s Invoices may remain under seal.

Hon. Valerie Figueredo □ □ November 26, 2025 Page 2 of 2 We thank the Court for its consideration.

Respectfully submitted, YANKWITT LLP | IO Benjamin Allee Ce: All parties (by ECF)